Boyd Gaming Corporation, F.K.A. The Boyd Group and Subsidiaries - Page 2

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               Thomas P. Marinis, Jr., J. Barclay Collins III,                        
          Sarah A. Duckers, and Charles L. Almond, for petitioners.                   
               Paul L. Dixon and Barbara S. Trethewy, for respondent.                 


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  The docketed cases are before the Court                  
          consolidated for purposes of trial, briefing, and opinion.                  
          California Hotel & Casino (CHC) petitioned the Court to                     
          redetermine respondent's determination of deficiencies of                   
          $81,761, $14,428, and $42,124 in its consolidated group's 1982,             
          1984, and 1987 Federal income tax, respectively.  Boyd Gaming               
          Corp. (Boyd) petitioned the Court to redetermine respondent's               
          determination of a $152,346 deficiency in its consolidated                  
          group's 1988 Federal income tax.                                            
               Following concessions by the parties, we must decide whether           
          petitioners' deductions for food and beverages provided to their            
          employees without charge on petitioners' business premises are              
          limited by section 274(n)(1).  In Boyd Gaming Corp. v.                      
          Commissioner, 106 T.C. 343, 344, 349 (1996), we held in summary             
          adjudication that section 274(n)(1) does not limit petitioners'             
          deductions if the food and beverages are a de minimis fringe                
          benefit under section 274(n)(2), which, in turn, requires that              
          petitioners provide the food and beverages to each of                       
          substantially all of their employees for the "convenience of the            





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